&EPA
Office of Solid Waste and Emergency Response
EPA 542-R-12-001
United States
Environmental Protection
Agency
Brownfields Road Map to Understanding
Options for Site Investigation and Cleanup
Fifth Edition
Investigate the Site
Assess the Site
Learn the Basics
www.brownfieldstsc.org/roadmap
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Brownfields Road Map Acknowledgments and Notice
ACKNOWLEDGMENTS
The U.S. Environmental Protection Agency (EPA) acknowledges and thanks the
following individuals who contributed to the review of this document:
Hugo Martmez Cazon, Vermont Department of Environmental Conservation
Ignacio Dayrit, Center for Creative Land Recycling
Evan Reeves, Center for Creative Land Recycling
Lenny Siegel, Center for Public and Environmental Oversight
Elizabeth Spinelli, Hudson County Economic Development Corporation, New Jersey
Laura Watchman, National Association of Local Government Environmental Professionals
Amy Versavich, Association of State and Territorial Solid Waste Management Officials
U.S. EPA Staff
Craig Boehr Melissa Friedland Bob Myers
Janet Brooks DebGoldblum Laurie O'Connor
Ann Carroll Sara Hartwell Deborah Orr
Philip Clappin Robin Hughes Patricia Overmeyer
Deana Crumbling Deborah Johnston Carlos Pachon
Cecilia De Robertis Diane Kelley Karen Peycke
Steve Dyment Jen Lewis Dan Schramm
Steve Ells Chip Love Janice Sims
RickEhrhart James Miles Paul Torcoletti
Jonathan Essoka Susan Morales
Linda Fiedler QueenieMungin-Davis
NOTICE
This document was funded by the EPA's Office of Solid Waste and Emergency
Response (OSWER) under EPA Contract EP-W-07-078. The document was subjected to
the Agency's administrative and expert review and was approved for publication as an
EPA document. The information in this document is not intended to revise or update
EPA policy or guidance on how to investigate or remediate brownfields or other land
revitalization sites. Mention of trade names or commercial products does not
constitute an endorsement or recommendation for use.
This document can be downloaded from the EPA's Brownfields and Land
Revitalization Technology Support Center at www.brownfieldstsc.org/roadmap.
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Contents Brownfields Road Map
CONTENTS
Introduction 1
Follow the Brownfields Road Map 5
Brownfields Road Map Graphic 7
Learn the Basics 9
Assess the Site 17
Investigate the Site 23
Assess and Select Cleanup Options 31
Design and Implement the Cleanup 37
Spotlights
1 Redevelopment Initiatives: Connecting Cleanup and Reuse 15
2 Supporting Tribal Revitalization 16
3 All Appropriate Inquiries 18
4 Project Life Cycle Conceptual Site Model 22
5 Data Quality: The Key to Making Robust Site Decisions 25
6 High-Resolution Site Characterization and In Situ Technologies Promote
Effective Cleanups 29
7 Vapor Intrusion 30
8 Challenging Cleanups 35
9 Understanding the Role of Institutional Controls at Brownfields Sites 36
10 Greener Cleanups 40
Online Appendices
A Guide to Contaminants and Technologies
B Brownfields and Technical Support Contacts
C Acronyms and Glossary of Key Terms
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Brownfields Road Map
Introduction
Introductio
for site investigation and cleanup
The Brownfields Road Map
The fifth edition features these
updates:
• Details to assist stakeholders
with planning their
brownfields project
• Revised "road map" graphic
• General planning assistance
for each phase of site
investigation and cleanup
• "Spotlights" on 10 current
issues and best
management practices
(BMPs)
• Online, searchable access to
more than 300 technical
resources and tools
• Online guide to
contaminants and
technologies typically
associated with brownfields
sites
• Expanded glossary of key
terms and concepts
The Brownfields Road Map to Understanding Options for Site Investigation and Cleanup,
Fifth Edition, provides a general outline of the steps in the investigation and cleanup of
brownfields sites and introduces brownfields stakeholders to the range of
technologies and resources available to them. The Road Map provides valuable
information for stakeholders typically involved in or affected by redevelopment of
brownfields sites, whether through public projects, private development or public-
private partnerships.
The first edition of the Road Map, published in 1997, provided a broad overview of the
EPA's Brownfields Program and an outline of the steps involved in the cleanup of a
brownfields site. Designed primarily for stakeholders who were unfamiliar with the
elements of cleaning up a brownfields site, the Road Map built awareness of the
advantages offered by innovative technologies. As the EPA's Brownfields Program
matured, the second (1999) and third (2001) editions were published to update
information and resources associated with the program and innovative technologies.
The fourth edition, published in 2005, provided additional resources and
supplemental information about emerging best practices, processes and initiatives
that influence the consideration and use of innovative technologies.
This edition incorporates a new approach to the Road Map through a streamlined
publication and a companion website of technical resources and tools. Stakeholders
can use the printed publication to learn about the general phases of the site
investigation and cleanup process and gain an understanding of the considerations
associated with typical brownfields sites. The Road Map website complements the
publication by providing direct access to technical resources and tools that provide
details about technology applications, methods and other site-specific concerns.
View the full contents of the Brownfields Road Map online at
www.brownfieldstsc.org/roadmap.
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Introduction Brownfields Road Map
This edition of the Road Map will help:
• New and less experienced stakeholders. The Road Map will help these users
learn about the EPA's Brownfields Program by introducing general concepts
and methods for site investigation and cleanup.
• Decision-makers who are familiar with the Brownfields Program but are also
interested in obtaining more detailed information. The Road Map provides
these users with up-to-date information about the applicability of
technologies and access to the latest resources that can assist them in making
technology decisions. In addition, BMPs that have emerged in recent years are
highlighted.
• Community members. The Road Map helps to encourage community
members to participate in the decision-making process by providing
information about the general site cleanup process, as well as guidelines and
mechanisms to promote community involvement.
• Stakeholders who hire or oversee site cleanup professionals. The Road Map
includes information to help stakeholders coordinate with many different
cleanup practitioners, such as environmental professionals, cleanup
contractors, technology vendors or staff of analytical laboratories. The Road
Map provides these stakeholders with a detailed understanding of each phase
in a typical brownfields site cleanup and presents information about the roles
that environmental practitioners play in the process.
• Regulators. The Road Map will increase the understanding by regulatory
personnel of site characterization and cleanup technologies and approaches.
The Road Map also serves as a resource that regulators can use to provide site
owners, service providers and other stakeholders with useful information
about the Brownfields Program.
• Other potential brownfields stakeholders. The Road Map helps other
stakeholders, such as financial institutions and insurance agencies, by
providing information for their use in assessing and minimizing risks
associated with brownfields redevelopment.
Disclaimer
The Road Map is not an official guidance document. Rather, it draws on the EPA's
experiences with brownfields sites, as well as Superfund sites, corrective action sites
under the Resource Conservation and Recovery Act (RCRA), and underground storage
tank (UST) sites. Specific conditions—such as the nature and extent of contamination,
the proposed reuses of the property, the financial resources available, and the level of
2 Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
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Brownfields Road Map
Introduction
support from neighboring communities—vary from site to site. Readers of the Road
Map are encouraged to explore opportunities to use the BMPs described in the
following pages in accordance with applicable regulatory program requirements.
This document provides general information and guidance regarding facilitating reuse
of properties. It does not address all information, factors or considerations that may be
relevant. This document is not legally binding. The word "should" and other similar
terms used in this document are intended as general recommendations or
suggestions that might be generally applicable or appropriate and should not be
taken as providing legal, technical, financial or other advice regarding a specific
situation or set of circumstances. This document may be revised at any time without
public notice. Any references to private entities, products or services are strictly for
informational purposes and do not constitute an endorsement of that entity, product
or service.
This document describes and summarizes statutory provisions, regulatory
requirements and policies. The document is not a substitute for these provisions,
regulations or policies, nor is it a regulation itself. In the event of a conflict between
the discussion in this document and any statute, regulation or policy, this document
would not be controlling and cannot be relied on to contradict or argue against any
EPA position taken administratively or in court. It does not impose legally binding
requirements on the EPA or the regulated community and might not apply to a
particular situation based on the specific circumstances. This document does not
modify or supersede any existing EPA guidance document or affect the Agency's
enforcement discretion in any way.
How to Submit Comments
The EPA invites comments from members of the
brownfields community to help ensure that any future
versions of the Road Map meet their needs. Please
submit comments to:
Carlos Pachon
U.S. Environmental Protection Agency
Office of Superfund Remediation and Technology
Innovation
pachon.carlostaepa.qov
(703) 603-9904
How to Obtain Additional Copies
A printed or hard copy version of this document can be
obtained from the following source:
National Service Center for Environmental
Publications
U.S. Environmental Protection Agency
P.O. Box 42419
Cincinnati, OH 45242-0419
(800) 490-9198 or (513) 489-8190
Fax: (513)489-8695
When you order the Road Map, please refer to
document number EPA 542-R-12-001.
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Introduction
Brownfields Road Map
About the EPA's Brownfields Program
Brownfields sites are defined as "real property, the expansion, redevelopment
or reuse of which may be complicated by the presence or potential presence
of a hazardous substance, pollutant or contaminant" (Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, as
amended, §101 (39)). The cleanup of brownfields sites improves and protects
the environment and may result in many benefits for the local community.
The EPA established its Brownfields Economic Revitalization Initiative in 1995
to empower states, communities and other stakeholders in economic
revitalization to work together to accomplish the redevelopment of
brownfields sites. With enactment of the Small Business Liability Relief and
Brownfields Revitalization Act in 2002, EPA assistance was expanded to
provide greater support for brownfields cleanup and reuse. Many states and
local jurisdictions also help communities adapt environmental cleanup
programs to the special needs of brownfields sites.
Summary of Brownfields
Program Accomplishments
as of January 201 2
Thousands of properties have been
assessed and hundreds of cleanups
have been completed with the
support of grants from the EPA's
Brownfields Program.
Measure
Properties Assessed
Cleanups Completed
Acres Made Ready
for Reuse
Cumulative
Results
18,204
702
33,444
Source: www.epa.aov/brownfields/
overview/bf-monthlv-report.html
Small Business Liability Relief and Brownfields Revitalization Act
Since 1995, the EPA's Brownfields Program has changed the way contaminated property is perceived, addressed
and managed. Enactment of the Small Business Liability Relief and Brownfields Revitalization Act (Public Law 107-
118; H.R. 2869) in January 2002 expanded the EPA's assistance by providing tools that the public and private sectors
could use to promote sustainable brownfields cleanup and reuse.
The law modified the EPA's existing brownfields grants and technical assistance program by:
• Increasing the funding authority up to $200 million per year
• Providing grants for assessments, revolving loan funds, direct cleanups and job training
• Expanding the entities, properties and activities eligible for brownfields grants, including sites such as mine-
scarred lands
• Expanding applicability to sites with petroleum contamination such as abandoned gasoline stations
• Providing authority for brownfields training, research and technical assistance
• Allowing local government entities up to 10 percent of the grant funds to be used to monitor the health of
exposed populations and enforce any institutional controls
The law changed and clarified Superfund liability:
• Provided liability protection for certain small-volume waste contributors and contributors of municipal solid
waste
• Clarified Superfund liability for prospective purchasers, innocent landowners and contiguous property owners
The law created a strong, balanced relationship between the federal government and state and tribal programs:
• Authorized up to $50 million per year for building and enhancing state and tribal response programs and
expanded the activities eligible for funding
• Provided protection from Superfund liability at sites cleaned up under a state program
• Preserved the federal safety net by detailing the circumstances in which the EPA can revisit a cleanup
• Clarified the state role in adding sites to the Superfund National Priorities List (NPL)
Additional information on the Brownfields Law is available atwww.epa.gov/brownfields/laws/.
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Brownfields Road Map
Follow the Brownfields Road Map
Assess
the Site
Investigate
the Site
Assess and Design and
Select Cleanup Implement
Options the Cleanup
General phases of the site investigation and cleanup process
Understanding the typical
progression of the site
investigation and cleanup
process ensures that the
proper groundwork is laid for
future phases.
Site investigation and cleanup
typically do not occur in the
linear sequence outlined in
the Road Map. At many sites,
several activities may be
undertaken concurrently,
while others recur throughout
the process. Similarly, many
technologies that are used to
characterize sites during the
investigation phase may also
be used during the cleanup
phase.
The fifth edition of the Road Map is composed of a publication and a companion
website. The publication presents the general phases involved in the investigation and
cleanup of a brownfields site and introduces the reader to a range of considerations
and activities. The website connects readers to the content of the publication online
and provides direct access to many technical resources and tools.
Overview of the Road Map Publication
The publication follows the process illustrated in the Brownfields Road Map graphic
(see page 7). The first section, Learn the Basics, discusses important factors that set the
stage for the investigation and cleanup of brownfields sites. The reader is introduced
to concepts, strategies and methods that can be applied to efficiently and effectively
prepare sites for reuse. Regulatory guidelines for the process also are introduced, and
technologies are discussed within the overall framework of selecting site
characterization and cleanup technologies. The remaining sections correspond to the
general phases of site characterization and cleanup, from site assessment through
implementation of cleanup remedies.
Spotlights - The Road Map "spotlights" focus the reader's attention on key issues,
processes and initiatives. They provide a quick look at topics relevant to brownfields
projects and identify how readers can obtain additional information. Technical
resources and tools for each spotlight are available from the companion website.
Online Appendices - Three appendices are provided at the Road Map Website.
Appendix A, Guide to Contaminants and Technologies, is an online guide to
contaminants found at more than 30 types of brownfields sites and the range of
technologies that may be appropriate for their characterization and cleanup.
Appendix B, Brownfields and Technical Support Contacts, provides information about
state, tribal and EPA regional and technical points of contact.
Appendix C, Acronyms and Glossary of Key Terms, defines acronyms and specialized
terms used in discussing and describing brownfields cleanup efforts.
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Follow the Brownfields Road Map
Brownfields Road Map
Features of the Road Map Website
www.brownfieldstsc.org/roadmap
The companion website provides easy access to resources and
tools. The website features:
• Technology resources organized by the general phases
of the investigation and cleanup of brownfields sites
• Tools to help stakeholders find resources and
publications with information that relates to their
brownfields sites
• An interactive guide to contaminants and technologies
• A closer look at each of the spotlight topics, including
links to related resources
• A list of acronyms and detailed glossary of terms
Quick access to EPA, state and tribal brownfields and
technical support contacts
'
Features
Guide to Contat
Technologies
Learn ibout toil ami rants typical/ found
mts and
Introduction
ne srownfieKs Road *
ickable Road Map
S i: Msi|--rd 10 Wtp rxsn-te
effectively wit!- tKr.-.ia'.
Follow the Road Map
Learn how the flaad Map publication suS tliis web
deanup ortessi, as ifcjstratefl in ins roaa map iHu
Learn the Basics
brownfieWs project.
IT* "s;»ttiShts" previse 3
quick, too* at t«sics rete-m
Guide to Contaminants
and Technologies
Spotlights with Links
to Additional Resources
All Appropriate Inquiries Rule:
Presents detailed information about
contaminants found at brownfields
sites and technologies used to
investigate and treat them.
Provides access to the spotlights
presented in this publication and
links to relevant resources.
Resources can be previewed or
downloaded from the companion
website.
Investigate the Site
information aaectet: taring tr* site investigator. p*as
an: reuse alternatives.
Assess and Select Cleanup Options
to i
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I The Brownfields Road Map illustrates
I the general steps involved in the
I investigation and cleanup of a
brownfields site.
Actual steps may vary depending on
site conditions and applicable state
and federal regulations. Stakeholders
should consult with appropriate
regulatory agencies throughout the
process and enlist qualified technical
and legal services.
View an interactive, online map at
www.brownfieldstsc.org/roadmap
that contains links to information
about the general phases and
spotlight topics.
Brownfields Road Ma
Learn the Basics
Before you begin down the path
outlined in the road map, it is
important to get prepared.
Preparation typically consists of
the following activities:
O Setting reuse goals
and planning
Understanding regulations,
regulatory guidelines and
liability concerns
Engaging the community
Identifying funding
Seeking professional
support
Site
*eu&e
Was the contamination
adequately removed,
contained or controlled?
Discovery of additional
contamination during cleanup
may require returning to the
Investigate the Site phase.
Consult appropriate
regulatory authorities
Begin
Here
the project still oc
given the cleanup options?
Is there a practical
redevelopment or
reuse alternative?
Consult appropriate
regulatory authorities
Proceed cautiously if your
site is likely to require costly
or complex cleanup. See the
spotlight on Challenging
Cleanups.
Can risks be managed adequately
to the satisfaction of stakeholders
in light of the proposed reuse?
Can redevelopment and reuse
occur without cleanup?
Is there an
immediate threat
to local residents?
Consult appropriate
regulatory authorities
Was contamination found?
View the spotlight on
Redevelopment Initiatives to
learn more about how EPA is
helping communities prepare
properties for reuse.
General phases of site
characterization and cleanup
Questions potentially
affecting the course of the
site characterization and
cleanup process
Additional investigation /\
may be required based on
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Brownfields Road Map
Learn the Basics
ear
asics
O Setting reuse goals and planning
• Understanding regulations, regulatory guidelines
and liability concerns
O Engaging the community
"""> Identifying funding
Seeking professional support
Redevelopment
Initiatives
Supporting Tribal
i Revitalization
Begin Your Trip Here
Begin here to learn about
factors and considerations that
affect cleanup at a brownfields
site. These "basics" are integral
to the cleanup process and the
overall success of the
brownfields project.
General concepts and terms
related to the investigation and
cleanup of brownfields sites are
introduced here and reinforced
throughout the publication.
Brownfields Stakeholders
A stakeholder is typically
considered an individual who is
part of the decision-making
process or can influence
decisions. Stakeholders for
brownfields projects may
include:
- Federal, state and local
agencies
- Local elected officials
- Local and regional
community development
agencies
- Developers
- Community members
- Tribes
- Property owners
- Academia
- Potentially responsible
parties (PRP)
- Private industry
- Non-profit organizations
Brownfields projects may be initiated for a number of reasons. A landowner may want
to sell a property to a prospective purchaser for development. A municipality may
want to clean up a parcel or area that has become a public hazard or eyesore, create
space for business development or build a park. A local comprehensive plan may call
for infill development of a certain type in a brownfields area. In these cases, the
brownfields process will be tailored to the specific end use envisioned for the
property.
Preparing a brownfields site for reuse involves more than the investigation and
cleanup of a property. The interests of many stakeholders must be integrated into the
overall redevelopment process. Cleanup strategies vary from site to site, depending on
factors such as intended end use, available funding, liability considerations, regulatory
requirements, the type and extent of contamination present, and the technologies
available for cleanup. At some sites, cleanup will be completed before the properties
are transferred to new owners. At other sites, cleanup may take place simultaneously
with construction and redevelopment.
Regardless of when and how cleanups are accomplished, a key challenge to
brownfields projects is to clean up sites in accordance with reuse goals and
appropriate laws and regulations. It is essential that stakeholders become familiar with
factors that play a significant role in the success of a brownfields project, such as
understanding applicable regulations, engaging members of the community,
identifying funding and obtaining professional support.
Setting Reuse Goals and Planning
From the outset, it is important to consider potential reuse goals. A reuse plan based
on those goals (or lack thereof) will govern most brownfields projects, from identifying
site investigation and cleanup standards, to obtaining competitive financing
potentially critical to the ultimate affordability or profitability of the project. Keep in
mind, however, that new information about contamination or cleanup needs may
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Learn the Basics
Brownfields Road Map
require that reuse plans be altered. Be prepared to develop a flexible
project plan that will evolve as information is collected, community
input is received and decisions are made about the cleanup approach.
Establishing reuse goals for a brownfields project also helps the project
team to define the decisions to be made throughout the project, which
is fundamental to selecting appropriate technologies for site
investigation and cleanup. When carefully selected, technologies enable
those responsible for the brownfields project to collect the data
necessary to support those decisions and accomplish the established
goals.
If reuse goals are not known at the beginning of the project, the
stakeholders should at a minimum make every attempt to identify the
general type of desired development, whether industrial, commercial,
residential or mixed-use. Absent that information, the most conservative
assumptions should be applied at every stage of the brownfields
project, a circumstance that could significantly increase the time and expense of the
project, potentially up to the point of making the project infeasible.
Understanding Regulations, Regulatory Guidelines and Liability Concerns
State and Tribal Response Programs
Many states have established formal
agreements with the EPA to facilitate
assessment, cleanup and redevelopment
of brownfields sites. The agreements,
referred to as Voluntary Cleanup
Programs (VCP), create a framework for
states and the EPA to coordinate the
oversight of the cleanup process. VCPs
provide technical assistance, liability
assurances and funding support to site
owners and developers. Learn more at
www.epa.gov/compliance/cleanup/
revitalization/state.html.
The EPA provides access to information
about tribal brownfields programs at
www.epa.gov/brownfields/state tribal/
tribe proas.htm.
The redevelopment of brownfields sites may be subject to a variety of
federal, state and local laws, regulations, policies and guidelines with
respect to the characterization and cleanup of the site. These sites also
may be governed by the standard practices of other government,
nongovernment and private institutions.
The applicable laws, regulations, policies and guidelines will vary by site,
depending on the regulatory authorities that have oversight authority
for cleanup. Therefore, it is important to research this information at the
outset and to work closely with the regulatory authorities throughout
the cleanup process. For example, state or local regulatory authorities
may oversee the cleanup of brownfields sites. These agencies should be
consulted to determine what, if any, site-specific requirements, reviews,
approvals or permits are applicable.
Example of Regulatory Requirement
If the proposed end use calls for
construction of a light industrial facility, it
may be appropriate, depending on state
and local regulatory requirements, to
compare the relevant cleanup standards
for industrial as well as commercial or
residential reuse standards. If the more
stringent standard required for
commercial or residential reuse is used,
additional cleanup and costs may be
required initially, but doing so provides
greater flexibility and avoids future
delay(s) if the proposed reuse is likely to
change.
At the EPA, the Office of Site Remediation Enforcement (OSRE) supports
cleanup and revitalization by issuing enforcement discretion guidance
documents, model enforcement documents, responses to frequently
asked questions, fact sheets and other documents. OSRE works with the
EPA regional offices to provide guidance on relevant enforcement tools to potential
The standards required will affect every
aspect of the project, from its overall cost
(which is generally greater as the
standards become more conservative) to
the selection of options for site
investigation and cleanup.
10
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Brownfields Road Map Learn the Basics
„ _ , „ , developers and owners of contaminated land. These
Key Resource for Regulatory
and Liability Concerns documents, along with current Superfund enforcement and
The Revitalization Handbook, updated and reissued brownfields PolicV and 9uidance documents, are available on
in 2011 by EPA's OSRE, is designed for stakeholders the EPA's website at http://cfpub.epa.gov/compliance/
involved in the assessment, cleanup and resources/policies/cleanup/superfund/. The EPA also can be a
revitalization of contaminated sites. The handbook . , . , . „ . , . . , . , , ...
, , ....... •• jmA valuable resource for brownfields stakeholders by providing
summarizes federal statutory provisions and EPA '^ a
policy and guidance documents useful for
managing liability risks associated with cleaning
regulatory and policy support to facilitate selection of
technologies. See Appendix B, Brownfields and Technical
up sites, and describes tools that stakeholders can Con Qn (he Brownfie,ds Road M websjte for
use to address liability concerns. The handbook,
including recent updates, is available at contact information.
www.e pa .q o v/co m p I ia n ce/reso u rces/
publications/cleanup/brownfields/handbook/.
Many of the standard practices are designed to help
brownfields redevelopment projects obtain financing from
public programs and private banks and institutions. Guidance and standards are
issued by government and nongovernment organizations, such as ASTM International
(formerly the American Society for Testing and Materials), the Federal Deposit
Insurance Corporation (FDIC), state and local economic development authorities and
private lenders.
Regulatory considerations at relevant phases of investigation and cleanup are
identified in the following sections. Stakeholders are encouraged to regularly consult
with appropriate regulatory agencies to ensure that requirements are properly
addressed throughout the project.
Engaging the Community
Encouraging active participation by members of the community who are most likely
to be affected by site cleanup and reuse plans contributes to the success of the
project. Engage the community to raise awareness, identify community concerns and
build support for cleanup efforts that will lead to
Key Resource for Community Engagement
redevelopment and revitalization of their community. To
EPA's Brownfields Program is designed to promote maxjmjze chances for ju e for how the
the active participation of communities in each
phase of the cleanup process so that revitalized community stakeholders will be identified and encouraged to
land offers the greatest local benefit. participate for the duration of the brownfields project, from the
A detailed overview of opportunities to engage investigation phases throughout cleanup.
the community in a brownfields project, including
the identification of public actions at each step, is it js important that brownfields decision-makers encourage
depicted graphically at www.epa.gov/oswer/ . f . , . .. .. ,
r M r / „ ,. , , , ; acceptance of reuse plans and cleanup alternatives by
engagementimtiative/brownfields.html.
involving members of the community through multiple
outreach methods such as public meetings, newsletters, publications, websites and
social networks. For an individual site, the community should be informed about how
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Learn the Basics
Brownfields Road Map
the use of a proposed technology might affect redevelopment plans
or the adjacent neighborhood. Consider how the people living in or
near the site might be affected by cleanup activities and the intended
reuse of the property; plan early and appropriately for how cleanup
decisions and their potential impact will be shared with the
community.
The EPA assists brownfields communities by directing its members to
appropriate resources and providing opportunities to network and
participate in sharing information. A number of websites, databases,
newsletters and reports provide opportunities for brownfields
stakeholders to network with other stakeholders to identify
information about cleanup and technology options. Details about the EPA's
community engagement efforts by the Office of Solid Waste and Emergency Response
(OSWER) are available on the Community Engagement Initiative website at
www.epa.qov/oswer/enqagementinitiative/. Helpful tools and data focused on
community engagement at UST sites are provided on the EPA's Office of Underground
Storage Tanks (OUST) community engagement website at
www.epa.qov/oust/communityenqaqement/.
Identifying Funding
Technical Assistance for Communities
The EPA's Technical Assistance to
Brownfields Communities (TAB) program is
a valuable community resource. Organized
to provide geographically based assistance,
the TAB program increases understanding
of technical issues associated with
brownfields sites and helps community
members learn how to participate in
cleanup and revitalization activities.
Details, including how to request technical
assistance, are provided online at
www.epa.gov/brownfields/tools/.
One of the most important factors to consider at the beginning of a
brownfields project is funding. Simply put, the project cannot be
initiated or undertaken until funding sources are identified and funds
are secured. The success of a brownfields project is determined by the
ability of the stakeholders to establish a funding package that covers
the project costs from planning and assessment through cleanup and
long-term monitoring. Most brownfields projects leverage funding
from a variety of sources. Be mindful that securing funding can be a
lengthy process.
The range of potential sources and the means of securing funds can
appear overwhelming, but fortunately, many helpful resources and
tools are available to guide stakeholders in exploring funding options.
Funding for the investigation and cleanup of brownfields sites is available from
federal, state and public and private sources. Programs available at the federal level,
such as the EPA, typically involve awarding grants and providing technical assistance
to communities and stakeholders. Other federal programs, such as the U.S.
Department of Housing and Urban Development, the U.S. Department of Agriculture,
the U.S. Department of Transportation and the U.S. Department of Commerce, also
EPA Brownfields Grants
The EPA offers funding for brownfields
assessment, cleanup, revolving loan fund
and environmental workforce development
and job training grants. Learn more about
the EPA's brownfields grants at
www.epa.gov/brownfields/grant info.
Summaries of the types of grants are
provided, including fact sheets, guidelines,
resources, eligibility requirements, funding
levels and tips for applying. Specific
instructions and deadlines for applying for
the EPA's brownfields grants are provided
atwww.epa.gov/brownfields/applicat.htm.
12
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Brownfields Road Map Learn the Basics
Key Resource for State Programs
provide funding and technical assistance for brownfields
.... . ,, , , , projects. State programs are a valuable option as well, as
Published in 2011 by the EPA's Office of Brownfields K J K y K
and Land Revitalization (OBLR), the State Brownfields states are increasingly offering flexible tools, financial
and Voluntary Response Programs: An Update from the assistance, tax incentives and other redevelopment
States provides helpful information about programs support tQ promote dea and reuse of brownfie|ds sites.
and tools available for brownfields projects through
state programs. State-specific details are provided,
including financial assistance tools, such as funding, tax
incentives and environmental insurance; funding
sources, amounts and whether the state program
www.epa.gov/brownfields/state tribal/pubs.htm.
At the beginning of the project, explore federal, state and
local programs to learn about the sources of funding
available and the process for applying for and securing
focuses on specific types of properties; liability relief , , , , , , , , ,
provisions; and contact information. fundm9'Take advanta9e of the manV helPful resources
available on the EPA's Brownfields website
The resource is available online at
(www.epa.gov/brownfields/qrant info/) to learn about the
EPA's grant programs, details about federal tax deductions
and to access state response programs, including points of contact and success
stories.
Seeking Professional Support
Most decision-makers for brownfields sites will require technical and legal assistance
to fully understand the complexities of investigating and cleaning up contaminated
sites. Depending on the complexity of a particular site, decision-makers may need the
assistance of environmental practitioners with expertise in geosciences, chemistry,
engineering, field sampling, redevelopment and other disciplines; cleanup
contractors; technology vendors; and staff in analytical laboratories to perform many
of the activities required to investigate and clean up the site. The inclusion of these
professionals and other experts as members of a brownfields project team is
recommended to ensure the successful completion of the brownfields project.
.,..„, . , Regulations applicable to brownfields projects in some states require the
Using Certified Professionals J
participation of certified or licensed environmental professionals to help
Some states require the , , , , ,
participation of certified or licensed 9uide the site investigation and cleanup process. For example, the EPA's final
professionals to help guide the site rule for All Appropriate Inquiries (AAI) requires that AAI investigations be
investigation and cleanup process. performed or supervised by individuals who have specific certification or
licensure, education or experience levels that meet the definition of
"Environmental Professional" provided in the AAI final rule. A request for proposal
(RFP) is often used as the procurement mechanism to obtain the services of such
professionals (individuals or a firm). The RFP requests potential service providers to
submit a proposal that addresses the approach, qualifications and cost estimate for
the services requested. The RFP can include specifications that encourage prospective
bidders to think "outside the box" and consider innovative approaches. Selection
criteria outlined in the RFP should include the demonstrated experience of the
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Learn the Basics Brownfields Road Map
individuals or firm in developing valid options for using streamlined strategies and
innovative technologies at brownfields sites and in successfully implementing the
selected options. Demonstrated experience can include resumes, project descriptions
and letters of recommendation.
Seeing the Bigger Picture - Related EPA Initiatives
As the EPA's Brownfields and Land Revitalization Program has matured over the years
to address new challenges and evolving stakeholder needs, new programs and
initiatives have been undertaken to better integrate efforts to clean up and reuse
brownfields sites. See Spotlight 1, Redevelopment Initiatives: Connecting Cleanup
and Reuse, and Spotlight 2, Supporting Tribal Revitalization, for a brief overview of
several programs and initiatives that are designed to help the brownfields community
integrate revitalization efforts, including principles such as sustainability, renewable
energy and smart growth. In addition to setting policy and providing guidelines, these
programs offer extensive resources to help brownfields stakeholders apply lessons
learned from the experiences of other redevelopment projects.
Find Helpful Resources
Visit the Brownfields Road Map website for resources to learn more about
general concepts and factors for the cleanup of brownfields sites. The
Learn the Basics resources provide more general information than the
technology resources identified in the following chapters.
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Brownfields Road Map
Learn the Basics
Spotlight 1
Redevelopment Initiatives:
Connecting Cleanup and Reuse
Listed below are highlights of several EPA prog rams and initiatives focused on helping brownfields stakeholders learn how to
more efficiently and collaboratively prepare contaminated properties for reuse.
Initiative / Program
Available Resources / Additional Details
Land Revitalization Program - The Land Revitalization Program's mission is
to restore land and other natural resources into sustainable community assets
that maximize beneficial economic, ecological and social uses and ensure
protection of human health and the environment. The Land Revitalization
Program promotes sustainable approaches to remediation as the norm across
all EPA contaminated land programs, recognizing cleanup and reuse as
mutually supportive goals. The program emphasizes that the consideration of
anticipated property reuse should bean integral part of cleanup decisions.
Resources, policies and guidance, success
stories and details about the program are
available online at www.epa.gov/
landrevitalization. Links to program-specific
information, including details about grant
and funding resources, are also provided.
Brownfields Area-Wide Planning Pilot Program - This program supports
community involvement in locally based efforts to plan for the assessment,
cleanup and reuse of brownfields sites within a defined area. Through grants
and technical assistance, the program promotes land revitalization on a larger
scale than a single brownfields site (for example, revitalization of a
neighborhood, block or corridor affected by a brownfields site) and promotes
community engagement in the planning for brownfields revitalization efforts.
Details about the pilot program, including
pilot project fact sheets and information
about applying for funding, are available at
www.epa.gov/brownfields/
areawide grants.htm.
Petroleum Brownfields Action Plan: Promoting Revitalization and
Sustainability - The EPA launched this program in 2008 to address the
unique challenges associated with the cleanup and reuse of brownfields sites
with petroleum contamination.
Visit www.epa.gov/oust/
petroleumbrownfields to access the action
plan, progress reports, success stories,
grants information and other resources.
Smart Growth - The EPA's Smart Growth program provides tools and
resources to help people implement sustainable development strategies that
promote healthy, attractive and economically strong communities.
Integrating community, environmental and the economic considerations,
applying smart growth principles to brownfields sites can lead to the
selection of more valuable and sustainable reuse alternatives.
To learn more about the EPA's Smart
Growth program, visit www.epa.gov/
smartgrowth/. Resources, tools, technical
assistance and examples of successful
smart growth approaches are provided.
Re-Powering America's Land - Launched in 2008, this initiative encourages
renewable energy development on current and formerly contaminated land
and mine sites. Efforts focus on identifying the renewable energy potential of
sites and providing useful resources for communities, developers, industry
and state and local governments and others interested in reusing these sites
for renewable energy development.
Visit www.epa.gov/oswercpa/ for
information about funding sources,
technical assistance, fact sheets, interactive
mapping tools to identify sites with
renewable energy potential, webinars and
federal and state incentives.
Superfund Redevelopment Initiative (SRI) - Since 1999, SRI has helped
communities return some of the nation's worst hazardous waste sites to safe
and productive uses. In addition to cleaning up these Superfund sites and
making them protective of human health and the environment, the Agency is
working with communities and other partners to consider future use
opportunities and integrate appropriate reuse options into the cleanup
process. The EPA is also working with communities at sites that have already
been cleaned up to ensure long-term stewardship of site remedies and to
promote reuse.
Webinars, success stories, tools and
resources, community support,
demonstration project fact sheets,
partnership information and complete
details about the initiative are available
online at www.epa.gov/superfund/
programs/recycle/.
Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight ri.cfm.
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Learn the Basics
Brownfields Road Map
Spotlight 2
Supporting Tribal Revitalization
Federally recognized tribes in the United States develop their own
environmental policy, establish standards and manage their
environmental protection and natural resource management programs.
Tribes can establish a brownfields program or a Tribal Response Program
to address and reuse contaminated lands. The EPA provides technical
and financial assistance to tribes for the restoration of contaminated
tribal lands and the implementation of more effective approaches to
attaining productive reuse of sites.
Financial and Technical Assistance Provided by the EPA
• State and Tribal Response Program Grants can be used to establish
new or enhance existing environmental response programs.
• Assessment, Revolving Loan Fund and Cleanup Grants (ARCGrants)
fund activities for sites contaminated by petroleum, hazardous
substances, controlled substances or mine-scarred land.
• Job Training Grants fund opportunities for residents to take
advantage of jobs created by the assessment and cleanup of
brownfields sites.
• Technical Assistance to Brownfield Communities (TAB) Grants provide
technical or training assistance to increase community
understanding and participation in the brownfields remediation
process.
• Targeted Brownfields Assessments (TBA) provide direct technical support for environmental assessment activities, which
may be an option for sites that are not strong candidates for competitive grants.
• Limited funding also is available through Superfund cooperative agreements for program development and site
assessment.
Tribal Highlights
• The Passamaquoddy Tribe used funds from the Tribal Response Program to create an inventory of contaminated
properties. The tribe also received assistance from the Maine Department of Environmental Protection's Brownfields
Program to assess the Sipiyak Corner Store property, which included a vacant gas station. Discovery of contaminated soil
resulted in the removal of USTs, and the site is now ready for reuse.
• The Absentee Shawnee Tribe has used funds from the EPA Brownfields Job Training grants to train more than 124
students on topics ranging from asbestos remediation to Hazardous Waste Operations and Emergency Response
(HAZWOPER) health and safety training. Graduates of the training program have been employed by the Tribe's Office of
Environmental Protection and other environmental firms and formed their own remediation company.
For More Information
Additional information about tribal grant funding guidance, tribal response program publications and tribal brownfields
programs is available online at www.epa.gov/brownfields/state tribal.
SHARED SUCCESS
iBMEIlg
^www Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight_tr.cfm.
Road Map
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Brownfields Road Map
Assess the Site
The site assessment is a
crucial step in the brownfields
process because the need for
any further environmental
investigation and cleanup will
depend on whether potential
environmental concerns are
identified.
Collect and Assess Information about Your Brownfields Site
The purpose of this phase is to evaluate the potential for contamination at a particular
site by collecting and reviewing existing information. A site assessment includes a
review of site and government records, a site visit to visually inspect existing site
conditions and identify any potential releases of hazardous substances, and interviews
with people who have direct knowledge about historical uses of the site, past and
current operational practices, and any potential for related environmental concerns.
ASTM International
Phase IESA
The site assessment is usually
conducted consistent with ASTM
International Phase I ESA practices,
which are the generally accepted
standard for evaluating a site for a
potential release of hazardous
substances or petroleum products into
site structures, soil, groundwater,
surface water, sediment and indoor air.
Each instance when the available
information suggests that a release of
hazardous substances or petroleum
products may have occurred is
designated as a recognized
environmental condition (REC).
For more information about the ASTM
International standard practice, visit
www.astm.org/Standards/E1527.htm.
A site assessment—typically beginning with a Phase I Environmental Site
Assessment (ESA)—is essentially a compilation and review of available
information. Efforts conducted during a site assessment to evaluate the
history of a site and determine whether contamination is present also can
be used to comply with the requirements of an AAI investigation.
Conducting an AAI investigation is one element required for obtaining
liability protection. See Spotlight 3, All Appropriate Inquiries, for details on
the requirements for performing an AAI investigation.
During the site assessment phase, it is important to consider the activities
and requirements described in the subsequent chapters and determine
how they may be affected by initial site assessment information. Because
the information obtained in this phase will determine whether any future
site investigation work must be done at the site, assessment activities
should be thorough and tailored to meet site- and project-specific data
objectives. The information collected during this initial phase of the
brownfields project is extremely important for providing early indications
of whether the property may need to be cleaned up to support its
intended reuse and can provide a preliminary indication of the available
cleanup technologies.
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Assess the Site
Brownfields Road Map
The information collected about the site is typically organized into a
project life cycle conceptual site model (CSM). The CSM is a valuable
planning tool and framework for designing site activities and facilitating
communications of the project team and with stakeholders. See
Spotlight 4, Project Life Cycle Conceptual Site Model, for details and access
to examples of CSMs.
Community Benefit
The CSM is useful for sharing
information with community members
about the environmental conditions of
the site, goals for the cleanup, data to
be collected and decisions to be made.
All Appropriate Inquiries is the process of evaluating a property's history and
environmental condition to determine whether any contamination may be
present. AAI investigations are required to be performed for a future properly
owner to be considered an innocent landowner, contiguous property owner, or
bona fide prospective purchaser under the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA), or Superfund.
Conducting AAI Investigations
AAI investigations must be performed within a certain time frame and manner and
by individuals with specific qualifications to be considered compliant with the AAI
final rule, published at 40 Code of Federal Regulations (CFR) Part 312 (effective November 1,2006). Specific requirements
include the following:
• An AAI investigation must be performed or updated within 1 year prior to acquisition of the property.
• Specific activities required by the AAI final rule that must be performed or updated within 180 days before acquisition of
the property include an onsite visual inspection, review of government records, interviews with previous and current site
owners and searches for environmental cleanup liens.
• AAI investigations must be performed or supervised by individuals who have specific certification or licensure, education
or experience levels that meet the specified definition of "Environmental Professional" provided in the AAI final rule.
• The findings of an AAI investigation must be documented in a written report. The report must include:
1) An opinion as to whether the inquiry identified conditions indicative of releases or threatened releases of hazardous
substances on, at, in or to the subject property,
2) An identification of "significant" data gaps if they affect the ability of the environmental professional to identify
conditions indicative of releases or threatened releases,
3) Qualifications and signature of the environmental professionals, and
4) An opinion regarding additional appropriate investigation, if the environmental professional has such an opinion.
• AAI requirements may be met using the ASTM El 527-05 Phase I Environmental Site Assessment Process or ASTM E2247-
08 Phase I Environmental Site Assessment Process for Forestland or Rural Property.
For More Information
Visit the EPA's All Appropriate Inquiries website at www.epa.gov/brownfields/aai/ for fact sheets about AAI, access to the EPA's
published final rule on AAI (40 CFR Part 312), and other information.
Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight_aai.cfm.
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Brownfields Road Map
Assess the Site
Consider These Questions
Goals and Planning
» Has a redevelopment plan
been prepared or a
proposed end use
identified?
» Is a residential development
planned?
» If located in an industrial
area, will the site remain
industrial or be rezoned for
commercial use?
» If the site shows evidence of
contamination, who and
what will be affected?
» Will users of the property be
exposed directly to the site
soil, soil vapor, sediment or
surface water?
» Who will conduct long-term
monitoring and oversight,
particularly if residual
contamination is left in
place?
Oversight
» Is the site located in an area
targeted for
redevelopment? If so, is the
site being considered for
cleanup under a federal or
state Superfund cleanup
initiative?
» Will the site be entered into
a VCP? If not, what agency
(federal, state, local or tribal)
is responsible for managing
oversight of cleanup?
» Are there other federal,
state, local or tribal
regulatory requirements for
site assessment?
» Are there other regulatory
requirements for specific
contaminants likely to be
present on the site (for
example, lead-based paint
or asbestos)?
The needs and concerns of the community are also important considerations at this
early step. For example, it may be beneficial to develop social and economic profiles
and clearly identify what the community considers to be acceptable environmental
risks. Discussions and planning for how to identify stakeholders and keep them
engaged and actively participating throughout the entire project are important
activities to be undertaken in conjunction with site assessment.
Technologies that detect possible contamination in indoor air may be applicable at
this stage, as well as some real-time measurement technologies useful for assessing
contamination in soil, groundwater, surface water or other environmental media.
Examples of sampling and analysis technologies that may be applicable during this
phase are presented in the online Guide to Contaminants and Technologies at the
Brownfields Road Map website. However, the use of technologies is limited, since
much of the work at this phase typically involves a search of paper and electronic
records and interviews with current and previous site owners and workers.
Conduct Your Site Assessment
Typical activities that may be conducted during the site assessment phase are
indicated below. The list is intended as a general planning guide and is not a
comprehensive listing of assessment activities required under state and federal
regulations. Factors that should be considered are presented in the margin in the form
of questions. Fora better understanding of these requirements, such as the EPA's AAI
regulations, consult the references identified and work with appropriate regulatory
authorities.
• Establish the core technical team and take advantage of the team's expertise
to evaluate the adequacy of existing site information and identify potential
releases of hazardous substances or petroleum products.
o Identify and secure experts in geosciences, chemistry, engineering,
regulatory and field sampling.
o As required, consider additional support from individuals experienced in
risk assessment, biology, data management and quality assurance.
• Ensure that all brownfields stakeholders (such as regulators, community
members, property owners and technical staff, such as chemists and
engineers) are involved in the decision-making process.
• Identify future plans for reuse and redevelopment and goals of the site.
• Explore options for funding and technical assistance from the EPA.
o Consider applying for a brownfields assessment grant.
o Request technical assistance from the EPA's Targeted Brownfields
Assessment (TBA) program.
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Assess the Site
Brownfields Road Map
• Assess the site through an ASTM International Phase I ESA or its equivalent and
conduct AAI to determine whether contamination is likely present on site. In
general, perform a records search, visit the site and interview individuals with
knowledge of the site. The effort includes the following activities:
o Search relevant environmental databases. Commercial firms can cost-
effectively conduct database searches on a fee basis. The search will
consist of a review of federal and state databases, including but not
limited to: (1) the EPA's Comprehensive Environmental Response,
Compensation and Liability Information System (CERCLIS) of potentially
contaminated sites, (2) RCRAInfo, a national program management and
inventory system of hazardous waste handlers, (3) the National Pollutant
Discharge Elimination System (NPDES) of permits issued for discharges
into surface water and (4) state records of "emergency removal" actions
(for example, the removal of leaking drums or the excavation of explosive
waste).
o Identify past owners and the uses of the property by conducting a title
search and reviewing tax documents, city directories, sewer maps,
topographic maps, aerial photographs and fire, policy and health
department documentation related to the property.
o Analyze city government and other historical records to identify past use
or disposal of hazardous or other waste materials at the site.
o Interview property owners, occupants and others associated with the site,
such as previous employees, residents and local planners.
o Perform a walking inspection of the site and a visual evaluation of adjacent
and other local properties.
o Potentially collect samples to test for the presence of various contaminants
— for example, lead-based paint, asbestos and radon in structures.
o Plan additional investigations at the site and collect information as
necessary to investigate any releases of hazardous substances identified
during the site assessment and resolve any other uncertainties related to
the site.
• Coordinate with the project team to begin development of the project life
cycle CSM.
• Review the applicability of government oversight programs:
o Determine whether there is a state VCP and consult with the appropriate
federal, state, local and tribal regulatory agencies to include them in the
decision-making process as early as possible.
o Select the approach (such as redevelopment programs, federal regulatory
programs, property transfer laws or a state brownfields program) that is
required or available to facilitate the cleanup of the site.
o Identify whether economic incentives, such as benefits from state
brownfields programs or federal brownfields tax deductions, can be
obtained.
o Contact the EPA regional brownfields coordinator to identify and
determine the availability of EPA support programs and federal financial
incentives (see Appendix B, Brownfields and Technical Support Contacts).
Consider These Questions
(continued)
The Community
» What are the special needs
and concerns of the
community?
» How can meaningful
community involvement be
solicited?
» What environmental
standards should be
considered to ensure that
community stakeholders are
satisfied with the outcome
of the cleanup?
Site Conditions
» What is known about the
site?
» What records exist that
indicate potential
contamination and past use
of the property and adjacent
properties?
» What information is needed
to identify the types and
extent or the absence of
contamination?
» Has a previous Phase I ESA
been conducted?
» Have other environmental
actions occurred (such as
notices of violation)?
Funding
» Who will pay for the site
investigation and cleanup?
» Are private, state, city or
other federal agency funds
available?
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Brownfields Road Map
Assess the Site
• Decide how to encourage and incorporate community participation:
o Identify regulatory requirements for public involvement.
o Assess community interest in the project.
o Identify community-based organizations.
o Review any community plans for redevelopment.
• Examine factors that may impede redevelopment and reuse.
• Identify environmental or other site conditions that the community would
likely find unacceptable in light of the proposed reuse.
• Begin identifying potential sources for funding site investigation and cleanup
activities at the site, if necessary.
Find Helpful Resources
Visit the Brownfields Road Map website to identify and review resources
and tools that provide details about technology applications, methods and
other site-specific concerns.
Plan Your Next Step
The next course of action is determined by the results of the site assessment and what
has been learned about the site. Several possible outcomes and subsequent courses of
action are explained below.
Result of Site Assessment
No evidence of contamination is found
and there is no evidence of possible
contamination. Stakeholder concerns
have been addressed adequately.
Evidence of contamination is found
that poses a significant potential risk to
human health or the environment.
Course of Action
Confirm results with appropriate
regulatory officials before proceeding
with redevelopment activities.
Contamination possibly exists, as
indicated by the presence of RECs.
Contamination definitely exists, but no
site investigation has been conducted.
Contamination definitely exists and a
site investigation has been performed.
Contact the appropriate federal, state,
local, or tribal government agencies
responsible for hazardous waste. Based
on feedback of the government agency,
identify the cleanup levels required for
redevelopment, and proceed to the
Investigate the Site phase.
Proceed to the Investigate the Site phase.
Proceed to the Investigate the Site phase.
Proceed to the Investigate the Site phase
if additional investigation is warranted;
otherwise, proceed to the Assess and
Select Cleanup Options phase.
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Assess the Site
Brownfields Road Map
llfcall.
EXAMPLE: Preliminary CSM
.'CACHE LA
' POUDRE RIVER
LLC.END NOT TO SCALE
POUDRE RIVf B SITE
FORT COLLINS. COLORADO
A Conceptual Site Model is a graphical and written summary of what is
known or hypothesized about environmental contamination at a
brownfields site. An effective CSM is easy to understand and helps
technical teams, communities and stakeholders communicate with
each other and learn about the nature, extent, exposure and risk
associated with contamination. CSMs typically include graphical data
and written content, and may also include information such as site
features, geologic and hydrogeologic data, contaminant types,
transport and exposure pathways and potential receptors.
Benefits of CSM Use
CSMs are an important tool for the assessment and cleanup of
brownfields sites because they can assist stakeholders to:
• More fully understand site conditions and features
• Synthesize information from multiple sources
• Identify which information is unknown or uncertain about the site
• Define a plan for collecting additional information
• Obtain stakeholder agreement on site conditions and related project investigation, design and cleanup plans
Phases of the Project Life Cycle CSM
There are six phases of a life cycle CSM. It is important to understand that a life cycle CSM does not require the creation of six
individual CSMs, but rather the development of one CSM that evolves through all stages of site redevelopment. As additional
information about the site is known, the CSM becomes a powerful tool to support technical and communication needs.
V WATER TABLE (APPROXIMATE)
7— BENZENE AND NAPTHALENE PLUME BOUNDARY
1 i POST-PINEV CREEK ALLUVIUM (UPPER HOLOCENE)
! i BROADWAY ALLUVIUM (PLEISTOCENE!
I A PIERRE SHALE
I S S I LAMOftU.
MHBI CACHE LA POUDRE RIVER
PRELIMINARY
CONCEPTUAL SITE MODEL
U.S. EPA REGION VIII
IN COOPERATION WITH
BROWNf IELOS TECHNOLOGY SUPPORT CENTER
Project Life Cycle CSM Ph
Preliminary
Initial version of the
CSM developed using
existing data such as
historical information,
interviews with site
owners, information
from databases
managed by third
parties and other
important background
information.
A refined version of the
Preliminary CSM used
to identify data gaps
and areas where
uncertainties exist, such
as exposure pathways
and receptors. The data
gaps and uncertainties
serve as the basis for
developing detailed
plans for site
investigation.
Adds to the CSM
information obtained
during site
investigation, which is
used to help select
appropriate remedial
strategies and
technologies.
1 incorporates into the
CSM information at a
more detailed level, or
new considerations
that are identified, in
support of the
development of a
site-specific remedial
design.
^^^^^^^^^^^g
Information obtained
during remedy
implementation is
added, resulting in a
CSM that is used to
support efforts to
optimize remediation
effectiveness.
CSM includes
information obtained
from the construction
and completion of the
remedy, such as
contamination left on
site, institutional
controls (ICs) that have 1
been implemented and 1
monitoring
requirements.
Assess the Site
Investigate the Site
T
Assess and Select
Cleanup Options ^
Design and Implement the Cleanup
Road Map Steps: The six life cycle CSM phases relate to the general steps involved in the investigation and cleanup of a brownfields site.
For More Information
More details, including tools to assist in developing and using a CSM, and examples of CSMs, are available on the Triad
Resource Center website (www.triadcentral.org/tech/dsp sub.cfm?id=13).
jrces for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight csm.cfm.
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Brownfields Road Map
Investigate the Site
Information collected during
the site investigation phase
supports future decisions
about potential cleanup
options and reuse
alternatives.
Confirm Contamination and Identify its Source, Nature and Extent
Activities conducted during the site investigation phase are focused on confirming
whether any contamination exists at a site, locating the source of contamination,
characterizing its nature and extent and identifying possible threats to the
environment or to any people living or working nearby. For brownfields sites, the
results of a site investigation are used to identify and quantify the risks associated with
potential contamination and to develop effective cleanup plans. The results may also
be used to set specific goals for the cleanup and assess anticipated cleanup costs,
which will help stakeholders evaluate the economic viability of the project.
ASTM International Phase II ESA
Environmental site assessments are
conducted to evaluate existing
environmental problems from past
operations and potential
environmental problems from current
or proposed operations at a site. The
primary objective of conducting a
Phase II ESA is to confirm and evaluate
the RECs identified in the Phase I ESA.
For more information about the ASTM
International standard practice, visit
www.astm.org/Standards/E1903.htm
A site investigation, also referred to as a Phase II ESA, is designed based on
the results of the Phase I ESA discussed in the preceding chapter. The
Phase II ESA includes the analysis of samples of building materials and
environmental media, such as soil and soil gas, groundwater, surface
water, sediment and indoor air. For sites where contamination is
confirmed, additional site investigation efforts are used to delineate the
nature and extent, source locations and significance of contamination for
the purpose of supporting subsequent cleanup and reuse decisions.
Contaminant migration pathways through media (for example, soil,
groundwater and air) are also examined in relation to potential receptors
(for example, humans, animals and plants). A baseline risk assessment to
| quantify risk to human health and or the environment may be conducted.
Examples of investigation technologies that may be useful during this phase are
presented in the online Guide to Contaminants and Technologies available at the
Brownfields Road Map website.
Many technologies are available to assist those involved in brownfields cleanup to be
more effective in their efforts. In addition, BMPs for site investigation and cleanup
have emerged in the last few years. These BMPs incorporate systematic project
planning, dynamic work strategies and the use of real-time measurement
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
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Investigate the Site
Brownfields Road Map
technologies to accelerate and improve the cleanup process by reducing costs,
improving decision certainty, and expediting site redevelopment. For example,
effective systematic planning of the investigation can result in lower overall project
costs, while dynamic work strategies can reduce or eliminate the need for multiple
mobilizations to a site to complete investigations.
Real-time measurement technologies provide information about contamination at the
site that the project team can analyze while in the field. Used collaboratively with off-
site laboratory analysis, the real-time data and field-based analytical methods can
provide a more precise picture of the conditions at the site (for example, the extent of
contamination and migration pathways). See Spotlight 5, Data Quality: The Key to
Making Robust Site Decisions, for details about the benefits of using real-time
measurement tools and methods. A thorough site investigation will improve
understanding about the true conditions of the site, which reduces uncertainty and
improves stakeholder confidence in the decisions made.
Types of Uncertainty
Using BMPs helps to reduce a
variety of uncertainties associated
with brownfields projects.
Analytical Uncertainty
Methods, Quantity, Quality,
Validation, Appropriate Use
Sampling Uncertainty
Media, Methods, Location,
Distribution, Depth, Purpose
Site Decision Uncertainty
Risk, Action Levels, Remedy,
Stakeholders, Acceptability
Resource Uncertainty
Funding, Schedule, Personnel,
Logistics, Weather
Provided below is an overview of using BMPs to investigate a brownfields site and the
benefits of their use.
Best Management Practices for Investigating a Brownfields Site
Linking Decisions, Data and Technologies
Decisions to be Made
Project Planning
and Technical Performance
Project Life Cycle CSM
Preliminary Planning
• What are the site redevelopment goals?
Systematic Planning
• What decisions are needed to support site goals?
• What information is needed to make decisions?
• What level of data quality is required?
• What data gaps or uncertainties exist?
Work Plan Development
• How should data be collected?
• What are the appropriate sampling and analysis
designs to generate data of acceptable quality?
• Can real-time measurement technologies be used
to collect data at the level of quality required?
Investigation Using Dynamic Work Strategies
• What do the data indicate?
• Is the delineation of contamination complete?
• Can robust decisions be made?
Preliminary Planning
Create CSM (Preliminary)
Systematic Planning
Update CSM (Baseline)
Work Plan Development
Based on data gaps identified
in the Baseline CSM
Investigation Using
Dynamic Work Strategies
Conduct additional dynamic
sampling as needed
Investigation Complete
Take appropriate action
based on the decisions made.
Update CSM
(Characterization Stage)
Update CSM to support
remedy selection, design
and implementation
Benefits of Using BMPs
• Improved site investigation information to support better redevelopment decisions
• More effective communication with stakeholders and the local community
• Increased confidence (reduced uncertainty) that cleanup plans are protective of human health and the environment
• Achievement of cleanup goals faster and at lower cost
24
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Brownfields Road Map
Investigate the Site
Spotlight 5
Data Quality: The Key
to Making Robust Site Decisions
Successful brownfields projects rely on environmental data that accurately
represent actual site conditions. These data must be of defensible quality and
provide sufficient detail to support robust decision-making so that a brownfields
project can proceed in a manner acceptable to all stakeholders and in accordance
with government regulatory and oversight programs (for example, EPA quality
assurance and state voluntary cleanup programs). Thus, data quality should be
considered during each redevelopment step, from determining the extent of
contamination and assessing risks to implementing the best cleanup approach.
Planning for Data Quality
Planning efforts for a brownfields project should address factors that affect data
quality, such as sampling design, sampling methods, analytical methods and
quality assurance/quality control (QA/QC) protocols. To ensure that defensible
quality data are collected, initial planning activities for brownfields projects should include:
• Clarifying project and data quality objectives (DQO)
• Identifying decisions and relevant supporting data that will be necessary to support project completion
• Developing a CSM to understand site conditions and identify key site data gaps
• Achieving consensus from project stakeholders on strategies and methods for data collection, evaluation and use
Using Field-based Methods to Reduce Site Uncertainty
Understanding the true conditions of the brownfields site reduces site
uncertainty—which is the key to making successful decisions. Increased
decision confidence among site owners, buyers and surrounding
communities decreases the likelihood of errors and omissions that could
negatively affect the site later. However, the cost of reducing uncertainty can
vary considerably based on the contaminants of concern and the
technologies and methods used to generate data.
Using real-time direct sensing tools and field-based analytical methods may
be a cost-effective way to reduce site uncertainty. They increase sampling
density and precision by enabling lower per-measurement costs than sole
reliance on conventional sampling and laboratory analysis methods. These
tools and methods can also increase the quality and value of conventionally
derived data by ensuring that samples are collected from the appropriate
locations, thereby increasing the representativeness of those samples. Project
teams can use data collected with field-based methods to make timely
decisions rather than waiting weeks to months for laboratory results and
formal project report generation.
For each brownfields project, steps should be taken to confirm that the field-
based methods to be used on the project site will provide adequate data quality to support decision-making. In addition,
results from field-based sensing and analytical methods should be confirmed using appropriate laboratory analytical methods.
For More Information
Information about data quality is available at www.triadcentral.org/req, including an overview of key concepts and
considerations for using real-time measurement systems. Additional resources are provided by the Interstate Technology and
Regulatory Council (ITRC) Incremental Sampling Methodology Team (www.itrcweb.org/teampublic ISM.asp) and the ITRC
Sampling, Characterization and Monitoring Team (www.itrcweb.org/teampublic SCM.asp).
gnug
Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight_dq.cfm.
nfields
i
Reduce uncertainty and
improve understanding of
site conditions with greater
sampling density
Offer lower
per-measurement costs
than conventional
sampling and laboratory
analysis
Support real-time decision
making rather than waiting
for laboratory results and
formal reports
Increase decision
confidence of stakeholders
Real-time is within a time frame that allows the project
team to react to the information while in the field.
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Brownfields Road Map
Conduct Your Site Investigation
Consider These Questions
The following activities are typically conducted during the site investigation phase.
Intended as a general planning guide, the list is not a comprehensive inventory of all
site investigation activities required under state and federal regulations. Factors to be
considered while planning the site investigation are presented in the margin in the
form of questions.
• Contact the EPA regional brownfields coordinator to explore the potential for
the project to qualify for a brownfields assessment grant and options for
technical assistance through the EPA's TBA program.
• If a Phase II ESA is warranted, consider funding sources (such as state
brownfields programs and federal tax deductions) for site investigation and
cleanup activities:
o Contact your state's brownfields program representative and the EPA
regional brownfields coordinator to identify the availability of state and
EPA support programs and federal financial incentives.
• In collaboration with stakeholders, use the results of the Phase I ESA to update
the project life cycle CSM. Identify critical data gaps as the basis for the design
of a Phase II ESA.
• Continue to work with regulatory agencies during the site investigation design
and data collection phases to ensure that regulatory requirements are being
properly addressed:
o Identify and consult with the appropriate federal, state, local and tribal
agencies to include their input as early as possible in the project.
• Invite community members to participate in discussions about the project
goals and objectives and in decisions about the site investigation design.
• Identify the proper mix of real-time measurement technologies and
conventional methods (such as off-site laboratory analysis) to investigate the
site and meet the required level of data quality.
• Research and ensure that proposed real-time measurement technologies and
the off-site laboratory can accurately detect all contaminants of interest to a
concentration that is lower than or comparable to the screening level
concentrations defined by the regulatory guidance and the agencies
overseeing the project.
• Conduct a Phase II ESA to define the environmental conditions associated with
the identified RECs at the site:
o Identify potentially viable site sampling and testing methods to confirm
geological and hydrogeological site conditions. For example, consider
consulting with a geophysical survey service provider to evaluate
approaches for cost-effectively addressing data gaps.
o Confirm and refine as necessary the human health and ecological
pathways for exposure to site contaminants.
Goals and Planning
» Can the need for cleanup be
assessed accurately from the
site assessment or from a
previous site investigation?
» Who or what could be
affected by the
contamination or cleanup
efforts?
» What happens if
contamination poses a
"significant threat" to local
residents?
» What happens if the
contamination is originating
from an adjacent property
or other off-site source?
» What happens if sampling
indicates that
contamination is originating
from a naturally occurring
source?
Oversight
» Will the site be entered into
astateVCP?lfso,willthe
investigation plan be
reviewed through the VCP?
If not, are there applicable
federal, state, local and tribal
regulatory requirements?
» What agency will oversee
the investigation? Does the
agency have suitable
standards or guidelines for
the proposed reuse?
The Community
» What issues has the
community raised that may
affect the site investigation?
» How will the results of the
site investigation be shared
with the community?
26
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Brownfields Road Map
Investigate the Site
Consider These Questions
(continued)
Site Conditions
» What are the potential
exposure pathways?
» Are the infrastructure
systems (roads, buildings,
sewers, public water
systems and other facilities)
contaminated? Could they
be affected by efforts to
clean up contamination?
» Is the site likely to be a
"challenging cleanup"? See
Spotlight 8 on page 35.
Options
» Has the team explored the
full range of technologies
that can produce data of the
quality required?
» What real-time technologies
are available to facilitate site
investigation and support
data collection efforts?
» Can the technologies
selected limit the number of
mobilizations to the site?
» Will the site investigation
involve iterative steps to
address data gaps that arise
during the project?
o Delineate the nature, extent, source and significance of any contamination
confirmed to be present.
o During the field investigation, evaluate results with other stakeholders to
achieve consensus that the associated data needs at each identified
release have been addressed.
o If applicable, evaluate whether and how the infrastructure systems (for
example, roads, sewers and structures) are affected by contamination.
• Update the Baseline CSM with data and observations obtained during the site
investigation. Use the Characterization CSM to identify and evaluate potential
cleanup options.
• Assess the risks posed to human health and the environment. Depending on
the planned end use of the property, other potential exposure pathways or
sensitive receptors may also require evaluation. Consider the human exposure
pathways of direct contact, ingestion, or inhalation of soil and dust, water and
indoor air.
• Depending on state regulatory requirements, perform a risk assessment to
identify site-specific cleanup levels when contaminant concentrations
confirmed at the site exceed regulatory screening levels.
• Evaluate confirmed site contamination in all affected environmental media in
terms of overall cleanup costs, including initial actions and long-term
operation and maintenance. Include potential cleanup options and
constraints that may affect redevelopment requirements, such as project
schedules, costs and potential for achieving the desired reuse.
• Share the updated CSM with members of the community to promote
understanding of the site conditions.
Find Helpful Resources
Visit the Brownfields Road Map website to identify and review resources
and tools that provide details about technology applications, methods and
other site-specific concerns.
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Plan Your Next Steps
The next course of action is determined by the results of the site investigation. Several
possible outcomes and subsequent courses of action are explained below.
Result of the Site Investigation
No contamination is found.
Course of Action
Consult with appropriate regulatory officials
before you proceed with redevelopment
activities.
Contamination is found, but does
not pose a significant risk to human
health or the environment.
Cleanup of the contamination found
probably will require a small
expenditure of funds and time.
Consult with appropriate regulatory officials
before you proceed with redevelopment
activities.
Proceed to the Assess and Select Cleanup
Options phase.
Cleanup of the contamination
probably will require a significant
expenditure of funds and time.
Residual contamination is
determined not to pose a risk to
local residents or the environment.
Determine whether redevelopment
continues to be practicable as planned, or
whether the redevelopment plan can be
altered to fit the circumstances; if so, proceed
to the Assess and Select Cleanup Options
phase.
Contamination is found that poses a
risk to local residents or the
environment.
Contact the appropriate federal, state, local or
tribal government agencies responsible for
hazardous waste. Compliance with other
programs, such as the EPA's RCRA and
Superfund programs, may be required.
28
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Investigate the Site
Spotlight 6
High-Resolution Site Characterization and In Situ
Technologies Promote Effective Cleanups
The advent of innovative site characterization technologies and strategies and the
development of more effective treatment methods may provide brownfields
stakeholders with new options for faster and more effective site cleanup.
New approaches to site cleanup, based on the use of in situ treatment technologies,
promote more targeted or "surgical" options for cleanup by enabling a better
understanding of subsurface features, contaminant distribution, volume, mass and
behavior over time.
High-resolution site
characterization (HRSC)
strategies and techniques define
contaminant distributions in
environmental media with
greater certainty.
Benefits of In Situ Treatment
Treatment using in situ methods reduces the time required
to clean up a site, decreases the amount of residual
contamination left at sites and minimizes the need for
long-term operations and maintenance. Together, these
benefits directly serve the interests of brownfields
stakeholders by:
• Expediting site redevelopment and reuse
• Reducing the requirement for engineering controls
(EC) and ICs
• Lowering or eliminating long-term expenditures
related to environmental protection measures
In situ treatments also provide the added value of supporting the goals of greener cleanups. For example, in situ treatments
reduce the amount of treatment materials and waste generation and handling.
3-D visualization of groundwater
contamination at a brownfields site
Why High-Resolution Site Characterization?
Design and implementation of in situ remedies requires an accurate
understanding of the nature and extent of subsurface
contamination, which can most efficiently and reliably be defined
using HRSC strategies and technologies. In addition, HRSC data can
be used to support the initial evaluation and selection of in situ
treatment technologies.
HRSC supports more effective use of in situ remedies by:
• Characterizing subsurface conditions critical to successful
remedy design at a scale that conventional investigation
methods are unable to attain
• Providing greater confidence that a site is fully characterized
by increasing data density
• Enabling more accurate estimation of contaminant mass and
volume through tighter source identification and delineation
• Improving the cost and performance of remedy monitoring by minimizing monitoring network needs.
Asa targeted strategy or as an overall BMP, HRSC can be applied to sites of any size under any regulatory program.
For More Information
HRSC is a new EPA initiative, and a formal definition for HRSC strategies and technologies has not yet been finalized. The
general concept and benefits of HRSC are being explained and communicated through a variety of EPA efforts. Technical
resources and other information about HRSC are available at www.brownfieldstsc.org/topics.cfm.
Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight_hr.cfm.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
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Brownfields Road Map
IDDDDI
EDJ
crawl space
DDDD
Dn_D
slab
basement
intrusion through cracks, holes, and gaps
vapor migration
contaminated soil
VOCs
T water table
contaminated
groundwater
Vapor Intrusion (VI) occurs when toxic vapors enter structures, become
concentrated and contaminate the indoor air. The vapors, which come
from chemicals in contaminated soil or groundwater, migrate through
foundation cracks, fractures in basement floors or walls, crawl spaces and
small gaps around pipes and utility lines. VI poses potential chronic and
acute health risks to anyone who breathes the air inside the affected
buildings.
Many contaminants can cause VI, including chemicals that readily
evaporate (volatile) and those that evaporate more slowly (semivolatile).
Vapor-causing contaminants are commonly referred to as volatile organic
compounds (VOCs). Examples of VOCs include gasoline, degreasers, dry-
cleaning solvents, naphthalene and some pesticides.
VI should be evaluated for all brownfields projects with possible VOC
contamination in the subsurface of the property or in the subsurface of nearby property. Because contaminated vapors can
migrate laterally in the soil and groundwater, the source does not need to be on the property to create a VI risk. Even green
spaces or properties with no history of industrial activity may be affected by VI if located near a contaminated property. Typical
brownfields sites with VI concerns include former gas stations, dry cleaners, landfills, automobile repair shops and former
manufacturing and chemical processing plants.
Considerations for Brownfields Projects
• Evaluating the potential for VI should begin early in the site assessment and investigation phases. Often, the only way VI
concerns can be solved is to adequately evaluate them before cleanup begins. Solutions may be easier to implement
and are generally less expensive if VI concerns are evaluated before construction is complete.
• The movement of volatile vapors can be difficult to quantify and initial environmental site assessments may not
accurately identify VI concerns. If a potential VI risk exists, appropriate sampling should be conducted during the site
investigation to evaluate potential exposure pathways.
• VI concerns should be incorporated into the project life cycle CSM to help define data quality objectives and identify
considerations for the cleanup design.
• Strategies to reduce or eliminate indoor air contaminant risks include:
o Remediating or controlling the sources of contamination in the subsurface
o Increasing natural building ventilation
o Ventilating the affected buildings with properly operated heating, ventilation and air conditioning systems
o Restricting the use of the facilities of concern
o Changing the location or altering the design of future buildings
• Operations, maintenance and monitoring of mitigation systems are generally necessary.
• Some states have specific VI guidance; environmental agencies should be consulted to ensure that up-to-date and
appropriate guidance is followed.
For More Information
In 2008, the EPA's Brownfields and Land Revitalization Technology Support Center published Brownfields Technology
Primer: Vapor Intrusion Considerations for Redevelopment. This primer contains detailed information about assessing
and mitigating VI concerns that will help stakeholders communicate with technical experts and contractors.
The EPA's VI website, www.epa.qov/oswer/vaporintrusion/, provides basic information and policy, guidance and technical
documents. VI resources also are provided on the CLU-IN website at www.clu-in.org/issues/default.focus/sec/Vapor Intrusion/.
™ Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight vi.cf
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Assess and Select Cleanup Options
The purpose of evaluating
various cleanup alternatives is
to identify technologies with
the capability to meet specific
cleanup and reuse objectives.
Identifying the Best Options
for Challenging Cleanups
The cleanup of some brownfields
sites may be complicated by site
conditions and the specific
contamination found on or near
the property. See Spotlight 8,
Challenging Cleanups,fora more
detailed discussion.
Evaluate Applicable Cleanup Alternatives for Your Site
Data collected during the site assessment and investigation phases are critical for
moving to this phase of a brownfields project. The project team and stakeholders use
the data and information known about a property to review and evaluate cleanup
options applicable to specific site conditions and consistent with cleanup and reuse
goals. Continuing to use the BMPs discussed in the previous sections ensures that
stakeholders can contribute meaningfully to the decision-making process because
they understand the site conditions and potential risks.
Sharing details about the options under consideration and inviting comment from
those in the community likely to be affected by the cleanup and reuse is an important
activity and contributes significantly to long-term community acceptance and support
of the selected cleanup alternative and the overall reuse goals. Encouraging
community involvement in these decisions ensures that the approaches taken
to address environmental impacts remain consistent with stakeholders' goals
and objectives.
After discussion and efforts to reach consensus among the various
stakeholders, decisions are made about the selection of cleanup alternatives,
including the use of technologies with the capability to meet specific cleanup
and redevelopment objectives. For brownfields sites, it also is important to
frame these discussions and decisions around budget considerations and work
schedule constraints so that the project remains financially viable.
Institutional controls are another important consideration during this phase. Examples
of these legal and administrative tools include easements, covenants, zoning
restrictions and posting advisories to increase community awareness of the
environmental conditions and cleanup activities at the site. See Spotlight 9,
Understanding the Role of Institutional Controls at Brownfields Sites, for more
information about institutional controls.
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Brownfields Road Map
Selecting the Cleanup Options for Your Site
Consider These Questions
The following list identifies activities that are typically conducted during the evaluation
and selection of cleanup options. The list is intended as a general planning guide and is
not a comprehensive inventory of all activities to be undertaken during this phase.
Factors to be considered are presented in the margins in the form of questions.
• Establish cleanup objectives that consider the end use and use applicable
standards, published state or federal guidelines, risk-based corrective actions
(RBCA), or site-specific risk assessment results.
• Communicate information about the proposed cleanup option to brownfields
stakeholders, including members of the affected community. Solicit the input
of the community in the site cleanup selection process and actively engage
community members in decision-making.
• Review general information about cleanup technologies and approaches to
become familiar with those that may be applicable to the contaminants and
geologic and hydrogeologic conditions present at the site. Focus on
identifying cleanup options that have a proven track record for sites with
similar contaminants and conditions:
o Use the resources available on the Brownfields Road Map website to
identify technologies.
o See Appendix A, Guide to Contaminants and Technologies, at the
Brownfields Road Map website for examples of technologies that are
appropriate for specific types of contaminants.
o Search existing literature that further describes the technology
alternatives.
o Analyze detailed technical information about the applicability of
technology alternatives.
• Enlist the help of a professional environmental practitioner with experience in
applying these technologies at similar sites.
• Assess the need for using ICs as part of the cleanup approach.
• Narrow the list of potential cleanup options that are most appropriate and
compatible for addressing site contamination and proposed reuse:
o Network with other brownfields stakeholders and environmental
practitioners to leverage their expertise.
o Determine whether sufficient data are available to support
identification and evaluation of cleanup alternatives.
o Analyze in more detail the applicability of technologies to the
contamination and conditions identified at a site.
o Evaluate the options against a number of key factors, including their
effectiveness, implementability and cost.
o Consider the benefits that some cleanup options may offer; for
example, less disruption to the community, potential reduction of
liability and long-term sustainability.
Goals and Planning
» Is there a consensus that site
characterization
uncertainties have been
sufficiently reduced?
» How is the appropriate and
feasible level of cleanup
identified?
Oversight
» Are there federal, state, local
or tribal cleanup
requirements?
» Are there prescribed
standards for the cleanup?
» Is there a state
environmental insurance
program?
The Community
» How can the community
participate in the review and
selection of options?
» What environmental
standards should be
considered to ensure that
community stakeholders are
satisfied with the outcome
and process of the cleanup?
» Are cleanup options
acceptable in light of
community concerns?
» Are cleanup options
compatible with regional or
local planning goals and
requirements?
Site Conditions
» Should risk-based
approaches be considered
for addressing exposure?
» Will the cleanup facilitate or
hinder the planned
redevelopment?
» Is there a need for ICs after
cleanup? If so, will ICs
facilitate or hinder
development?
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Brownfields Road Map
Assess and Select Cleanup Options
Consider These Questions
(continued)
Options
» Are the options acceptable
in light of community
concerns about protection
and reuse of the site?
» Are the cleanup options
compatible with regional or
local planning goals and
requirements?
» What are the short-and
long-term effects of the
cleanup technologies under
consideration?
» What options are available
to monitor the performance
of cleanup technologies?
» Are proposed ICs
appropriate in light of
community concerns?
» What plans, including
financial assurances, are
being made to ensure that
ICs remain functional as
long as contamination is
present?
» Does the proposed cleanup
approach place burdens on
future land owners or
occupants?
Funding
» How long will cleanup take?
» What will cleanup cost?
» Will schedule constraints or
the estimated cost adversely
affect the project's viability?
» Who will pay for long-term
costs to maintain the
cleanup, including any ICs?
o Determine the effects of various technology alternatives on
redevelopment objectives.
• Continue to collaborate with regulatory agency stakeholders to ensure that
regulatory requirements are properly addressed:
o Confirm that the agencies concur that site characterization
uncertainties have been sufficiently reduced to allow the process of
remedy selection and design to begin.
o Obtain agency input regarding the range of cleanup options under
consideration and input regarding any additional options.
• Contact the EPA regional brownfields coordinator to explore the potential for
the project to qualify for a brownfields cleanup grant or TBA support.
• Integrate cleanup alternatives with reuse alternatives to identify potential
constraints on reuse and time schedules and to assess cost and risk factors.
• To provide a measure of certainty and stability to the project, investigate
environmental insurance policies, such as protection against cost overruns,
undiscovered contamination and third-party litigation, and integrate their cost
into the project financial package.
• Select an acceptable remedy that not only achieves cleanup goals and
addresses the risk of contamination, but also best meets the objectives for
redevelopment and reuse of the property and is compatible and sustainable
with the needs of the community.
Find Helpful Resources
Visit the Brownfields Road Map website to identify and review resources
and tools that provide details about technology applications, methods and
other site-specific concerns.
A wide variety of chemical contaminants may be present at brownfields sites. Use the
online Guide to Contaminants and Technologies, available at the Brownfields Road
Map website, to get detailed
information about the applicability
of technologies for particular types
of brownfields sites. The table on
the following page lists examples of
brownfields sites and
Site Types
Which contaminants
are associated with
brownfields sites?
treatment technologies that are
described in the online guide.
Investigation
Technologies
What technologies may
be used to investigate
contamination?
Contaminant
Groups
What types of
contamination are
found and treated?
Treatment
Technologies
What technologies
may be used to treat
contamination?
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Assess and Select Cleanup Options
Brownfields Road Map
Examples of Brownfields Site Types and Treatment Technologies
Site Activities and
^^^^^^^^•^^^^^^^^^^^^^^H
Agricultural
Battery recycling and disposal
Chemical and dye manufacturing
Chlor-alkali manufacturing
Cosmetics manufacturing
Drum recycling
Dry cleaning
Gasoline stations
Glass manufacturing
Hospitals
Incinerators
Landfills, municipal and industrial
Leather manufacturing
Machine shops and metal fabrication
Manufactured gas plants and coal
gasification
Marine maintenance
Metal plating and finishing
Metal recycling and automobile salvage
Mining and mine-scarred lands
Operations*
• Painting and automobile body
repair
• Pesticide manufacturing and use
• Petroleum refining and reuse
• Pharmaceutical manufacturing
• Photographic film
manufacturing and development
• Plastic manufacturing
• Printing and ink manufacturing
• Railroad yards
• Research and educational
institutions
• Semiconductor manufacturing
• Smelter operations
• Underground storage tanks
• Vehicle maintenance
• Wood preservation
• Wood pulp and paper
manufacturing
e Depending on the type of site, level of contamination and risks posed, these
sites may be subject to other laws and regulations other than state VCPs, and it
may not be appropriate to manage them through the brownfields programs.
Check with EPA or the state on a site-specific basic to ensure assessment and
cleanup are conducted in accordance with the applicable statutory and
regulatory authorities.
reatment Technologies (Media)
Air Sparging (G)
Bioremediation (G/S)
Chemical Treatment (G/S)
Electrokinetics (G/S)
Flushing (G/S)
Incineration (S)
In-Well Air Stripping (G)
Mechanical Soil Aeration (S)
Multi Phase Extraction (G/S)
Nanoremediation (G/S)
Open Burn/Open Detonation (S)
Permeable Reactive Barrier (G)
Physical Separation (S)
Phytoremediation (G/S)
Pump and Treat (G)
Soil Amendments (S)
Soil Vapor Extraction (S)
Soil Washing (G/S)
Solidification/Stabilization (S)
Solvent Extraction (S)
Thermal Desorption (S)
Thermal Treatment (in situ) (G/S)
Vitrification (S)
G - Groundwater, leachate and surface water
S - Soils, sediments and sludges
Use the online Guide to Contaminants and Technologies to obtain more
details about the applicability of technologies at brownfields sites.
Plan Your Next Step
After cleanup options have been selected for your site, consider the following options:
Result of the Review of Cleanup
Options
The proposed cleanup option
appears feasible.
No cleanup option appears
feasible in light of the proposed
redevelopment and land reuse
needs (such as project milestones,
cost and intended reuse).
Course of Action
Proceed to the Design and Implement the
Cleanup phase.
Determine whether revising the redevelopment
plan remains a practicable option; if so, proceed
to the Design and Implement Cleanup phase.
Compliance with other programs, such as the
EPA's RCRA and Superfund programs, may be
required.
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Brownfields Road Map
Assess and Select Cleanup Options
Challenging Cleanups
n
The cleanup of some brownfields sites can be challenging
because the property is contaminated with chemicals that
are highly mobile, hard to find or difficult to treat.
Contaminants may be hard to clean up because:
• They are difficult to capture or separate
• They are located in hard-to-reach areas (for example,
fractured bedrock)
• They do not degrade naturally in the environment
Combinations of these factors present a variety of
challenges during site characterization and cleanup, which
can result in additional costs and time throughout a
brownfields project.
Types of Brownfields Sites with Challenging Cleanups
Many brownfields sites — including former gas stations,
electronics manufacturing facilities, auto service centers,
dry cleaning facilities, electroplating plants, wood
preservation sites and manufactured gas plants — have
been affected by contaminants that are challenging to
investigate and clean up. Some of the common
contaminants found at these types of brownfields sites
include dense non-aqueous phase liquids (DNAPLs),
polychlorinated biphenyls (PCBs), dioxins/furans, 1,4-
dioxane, methyl tertiary butyl ether (MTBE), perchlorate
and arsenic.
Assessment Considerations and Cleanup Options
Site assessment and cleanup should be designed with
strategies and technologies that address the unique nature
of the contaminants of concern. A solid understanding of
contaminant behavior in the environment is critical to
designing and implementing effective assessment and
cleanup. For example, contaminants that are hazardous at
very low concentrations may require costly, time-intensive
laboratory analysis to detect, as compared with
contaminants at higher concentrations, which might be
well-suited for assessment using cost-effective screening
technologies.
For More Information
The EPA provides reports and other informational materials
about various contaminants on the Contaminant Focus
section of the EPA's Contaminated Site Clean-Up
Information (CLU-IN) website at
www.cluin.org/contaminantfocus.
EXAMPLE: A Closer Look at DNAPLs
Two factors make DNAPLs a contaminant that is difficult to clean
up: (1) they do not easily dissolve in water (they are only slightly
soluble) and (2) they are heavier than water. Being denser than
water, DNAPLs tend to sink through groundwaterand permeate
into fine-grained soil units such as silt and clay. DNAPLs also can
migrate in multiple directions through fractures in bedrock.
Because of these properties, it can be difficult to predict DNAPL
migration pathways. Subsequently, DNAPLs in bedrock and fine-
grained soils can act as continuing sources of contamination,
which may cause long-term impacts to groundwater and pose a
significant challenge to site cleanup.
Used alone, traditional pump-and-treat systems may require
years to decades to clean up the groundwater. In these cases, it
is important to consider more effective alternatives, either
individually or in combination ("treatment train" or "combined
remedy"). Examples of such treatments include:
• Using microorganisms to break down the contamination
(bioremediation)
• Extracting DNAPL compounds from soil in vapor form with
a vacuum system and treating the gas to remove the
contaminants (soil vapor extraction [SVE])
• Applying chemicals to the contamination to break down
the DNAPLs into nonhazardous compounds such as water
and carbon dioxide (in situ chemical oxidation injection)
DNAPLs: A Significant Challenge
DNAPLs migrating through
unsaturated deposits
.water table
groundwater flow
Dissolved DNAPLs sinking
through saturated deposits
DNAPLs and dissolved DNAPLs migrating into bedrock
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Assess and Select Cleanup Options
Brownfields Road Map
I Spotlight 9 1
Understanding the Role of Institutional Controls
at Brownfields Sites
Institutional controls are a broad spectrum of administrative and legal
tools used to help minimize the potential for exposure to residual
contamination and to protect physical cleanup measures at
contaminated sites. ICs work by limiting land or resource use or by
providing information that helps modify or guide human behavior at a
site. ICs normally supplement ECs and are typically used in conjunction
with the overall cleanup remedy to support reuse. Long-term
considerations associated with 1C use, such as impacts on reuse and
funding requirements, must be carefully weighed against the costs and
benefits of permanent removal of contamination.
Types of ICs
• Proprietary controls involve private agreements that impose
restrictions on, or otherwise affect the use of, a property. Common
examples of proprietary controls are covenants, deed restrictions
and easements.
• Governmental controls, such as zoning, building codes,
groundwater use regulations and commercial fishing bans, restrict
land or resource use by the authority of a government entity.
Institutional Controls are
Administrative and Legal Tools
Types of ICs
•H Proprietary Controls
Governmental Controls
Enforcement and Permit Mechanisms
Informational Tools
Objectives of ICs
Minimize potential exposure to contamination
Restrict land use activities that might
compromise cleanup efforts
• Enforcement and permit tools with 1C components typically involve administrative orders, consent decrees and permits to
limit certain activities at a site or require a specific activity, such as monitoring and reporting.
• Informational devices, such as signs, markers and community outreach activities, provide notification and may
communicate risks about residual contamination that may remain on a site after a cleanup remedy has been undertaken.
Long-Term Considerations
• Identify the long-term costs and administrative implications of maintaining and enforcing ICs.
• Evaluate the potential use of ICs early in the cleanup process to plan appropriately for implementation, maintenance and
enforcement challenges.
• Consider and compare the costs of leaving contamination in place while maintaining ICs to the costs associated with
treating or removing contamination.
For More Information
The EPA's interim final guidance, "Institutional Controls: A Guide to Planning, Implementing, Maintaining, and Enforcing
Institutional Controls at Contaminated Sites," was published in the Federal Register in 2010 to request public comment. In 2009,
the EPA released a fact sheet that provides general information about the costs of ECs and ICs at brownfields sites. The fact
sheet, which includes an example of the use of ICs as part of a site cleanup, is available online at www.epa.gov/brownfields/
tools/Its cost fs.pdf. Another EPA fact sheet, "Addressing Long-Term Stewardship: Highlights from the Field," provides three
examples that highlight long-term considerations for maintaining and enforcing ICs. It can be viewed online at
www.epa.qov/brownfields/tools/lts fs 04 2008.pdf.
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Brownfields Road Map
Design and Implement the Cleanup
The final phase of preparing a
brownfields property for
reuse is designing and
implementing the cleanup.
During this phase, the
discovery of additional
contamination may require
further site investigation or
reassessment of available
cleanup options.
Maintaining stakeholder
participation during cleanup
promotes long-term
community acceptance and
support of the planned reuse
of the brownfields site.
Develop and Carry Out Your Detailed Cleanup Plans
During the cleanup design and implementation phase, the property is prepared for
redevelopment and reuse by carrying out the selected cleanup options, as described
in the preceding chapters. The design of the cleanup plan and implementation of the
chosen remedies involves close coordination with all other redevelopment efforts in
the immediate vicinity of the site.
Building on the comprehensive understanding of site conditions that has evolved
during the project, real-time technologies and dynamic work strategies can be used to
monitor and assess the results of cleanup activities. As in the site investigation phase,
these field-based methods can be used to evaluate progress toward the achievement
of the cleanup goals. Precise monitoring data help to minimize uncertainty and form
the basis for long-term monitoring strategies, including the use of institutional
controls.
In some cases, implementing the cleanup may lead to the discovery of additional
contamination or may reveal other complicating factors that require the project team
to conduct further site investigation and characterization. Additional site investigation
results may demonstrate that no practical alternatives exist for cleaning up the site to
meet the reuse goals of the project; if so, the site owner may need to consider
modifying the proposed land reuse plan or identifying other land use alternatives. See
Spotlight 8, Challenging Cleanups, for details about sites affected by contaminants
that are difficult to investigate and clean up.
Design and Implement Your Cleanup
Typical activities that may be conducted during this phase are outlined below, along
with factors to consider. The list is intended as a general planning guide and is not a
comprehensive inventory of all activities to be undertaken during cleanup of a
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Design and Implement the Cleanup
Brownfields Road Map
brownfields site. Factors to be considered are presented in the margin in the form of
questions.
• Review all applicable federal, state, local and tribal regulations and regulatory
guidelines to identify all specific requirements, including guidelines for state
VCPs.
• Continue to engage regulatory stakeholders to ensure that regulatory
requirements are being properly addressed:
o Confirm that the agency concurs with the design of the selected
remedy.
o Obtain agency input and concurrence on remedy assessment metrics
and alternative exit strategies.
• Contact the state brownfields program and the EPA regional brownfields
coordinator to identify and determine the availability of state and EPA support
programs.
• Develop conceptual plans for cleanup and subsequent monitoring that
incorporate technology options and consider the effect of any cleanup
activities on the proposed reuse of the property and the schedule for project
design or construction:
o Develop or review the schedule for completion of the project.
o Obtain a final amount for the grant funding available for project
development.
o Coordinate renovation and construction of infrastructure with cleanup
activities.
o Coordinate activities with developers, financiers, construction firms
and members of the local community.
• Establish contingency plans to address the discovery of additional
contamination during cleanup, including tools such as environmental
insurance policies.
• Continue to maintain stakeholder consensus and active community
participation during cleanup:
o Conduct public outreach meetings on a regular basis.
o Provide updates about the progress of cleanup activity.
o Share successes when important cleanup milestones are achieved.
o Inform the community about changes in activity that could affect
reuse plans.
• Implement, document and monitor the performance of the cleanup using the
accepted assessment metrics.
• Work with the state VCP, if applicable, and county or local officials to facilitate
the placement and implementation of institutional controls.
Consider These Questions
Goals and Planning
» How will the cleanup be
monitored and assessed?
» Will long-term monitoring
be required?
» Have alternative land use
strategies been developed?
Oversight
» Are there federal, state, local
and tribal requirements for
the design, installation and
monitoring of cleanup
activities?
The Community
» How will the community
participate in this phase?
» Are there examples of
effective community
engagement?
Site Specifics
» Can redevelopment and
cleanup activities be
performed concurrently?
» Will ICs facilitate or hinder
redevelopment? In the
future?
Options
» How will the cleanup design
affect long-term liabilities or
future use of the site?
» What can be done to protect
the community and other
property during cleanup?
Funding
» What a re the tradeoffs
between cost and meeting
project deadlines?
» How will long-term
monitoring be funded and
managed?
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Brownfields Road Map
Design and Implement the Cleanup
Find Helpful Resources
Visit the Brownfields Road Map website to identify and review resources
and tools that provide details about technology applications, methods and
other site-specific concerns.
Plan Your Next Steps
After the cleanup is completed, consider the following courses of action:
Result of Cleanup
Contamination has been adequately
removed, contained or controlled.
Additional contamination has been
discovered.
Long-term site monitoring and
operation and maintenance (O&M) of
the site remedy is required.
Course of Action
Consult with the appropriate regulatory
officials before you proceed with
redevelopment activities.
Consult with appropriate regulatory
officials to determine how to proceed
with cleanup activities. You may need to
return to the Investigate a Site phase to
conduct additional sampling to delineate
the extent and nature of the
contamination and assess the impact of
additional characterization and cleanup
costs on the overall viability of the project.
Return to the Investigate a Site phase to
evaluate options, including cost
considerations, for long-term monitoring
and O&M, and as necessary collect after-
performance samples for monitoring
cleanup.
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Design and Implement the Cleanup
Brownfields Road Map
Cleanup actions, while protective of the environment, also have their own
"environmental footprint"—they use energy, water and materials. To reduce this
footprint, cleanups can be performed in a "greener" manner by considering the
environmental effects of remedy implementation and incorporating options to
minimize the impact of cleanup actions. Principles of greener cleanup can be applied
throughout the site cleanup process, although it can be advantageous to consider
these options early to reduce the overall footprint of the project. The manner in which
these technologies or approaches are implemented can produce greener cleanups.
Greener cleanup BMPs can reduce environmental impacts while maintaining cleanup
objectives and ensuring that the remedy is protective of human health and the
environment.
Materials
& Waste I Ener9V \
r ^
Core
Elements
Land&
Ecosystems
Air
Water
Core Elements of Greener Cleanups
• Reduce total energy use by improving energy
efficiency and increasing use of energy from
renewable resources.
• Reduce air emissions of greenhouse gases and
criteria pollutants such as ozone, nitrogen
dioxide and sulfur dioxide.
• Protect water resources and reduce water use.
• Reduce waste and improve materials management.
• Safeguard the land and ecosystem during site cleanup.
Examples of Greener Cleanup BMPs to Consider for Brownfields Projects
• Buy local equipment and materials to minimize transportation costs.
• Use energy-efficient machinery or vehicles that use alternative energy.
• Provide an on-site collection and storage area for compostable materials for use
on site or by the local community.
• Use uncontaminated wastewater or treated water for tasks such as wash water,
irrigation, dust control and other uses.
• Consider renewable energy generation source development as a land reuse
option.
• Reuse salvaged building materials in redevelopment construction.
• Explore production of energy on site to operate remedial systems.
• Perform a renewable energy assessment to identify how renewable resources
could provide future energy needs.
• Incorporate low impact development (LID) techniques that view stormwater as a
resource rather than a waste source.
Examples of Sites Implementing Greener Cleanups
• Nitrate-contaminated groundwater at the Apache Powder site in Arizona was
treated by recirculating it through a gravity-driven, constructed wetland system
using a pump powered by solar energy.
• At the Grove Landfill site in Texas, salvaged site materials such as concrete and
wood were reused on site for erosion control, mulch and fill, and a tractor
powered by vegetable oil was used to remove on-site debris.
Government Support of Greener
Cleanups
The U.S. government encourages the
consideration of environmental
footprint reduction at many levels
ranging from Presidential Executive
Orders to Agency policies. Through
The Principles for Greener Cleanups,
issued by EPA's OSWER, the EPA
advances efforts to perform site
investigation and cleanup in a
manner that reduces the
environmental footprint while
maintaining primary cleanup
objectives. In addition, each of the
EPA's 10 regional offices has its own
"clean and green" policy encouraging
the integration of green remediation
practices into the cleanup process
within their states and territories.
Footprint Assessment Tools
A variety of tools, such as software
models and calculators, are available
to evaluate the environmental
footprint of remediation processes.
The Green Remediation Focus
Footprint Assessment website
(www.cluin.org/qreenremediation/
subtab b3.cfm) provides a summary
of available tools, which includes the
greener cleanup core elements
addressed by the tool, the form in
which the tool is available (web-
based, decision software or decision
matrix) and provides a link to
additional information.
For More Information
The Green Remediation Focus section
of the EPA's CLU-IN website at
www.cluin.org/qreenremediation
provides information on integrating
green remediation into cleanups and
case studies that describe green
remediation implementation.
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40
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Brownfields Road Map
Appendices
www.brownfieldstsc.org/roadmap
Brownfields and Technical Support Contacts
,
Acronyms
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Glossary
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Appendix A - Guide to Contaminants and Technologies
The guide contains detailed information about the types of contaminants
typically found at brownfields sites and the range of technologies that
may be appropriate for assessing and remediating them. The guide will
help stakeholders answer the following questions:
• Which contaminants are associated with brownfields sites?
• What technologies may be used to investigate contamination?
• What technologies may be used to treat contamination?
Information about site types, investigation technologies and treatment
technologies is cross-referenced by contaminant group. Stakeholders can
look up details about 7 general contaminant groups and more than 30
types of brownfields sites, explore technology options for investigating
contamination and review many treatment technologies.
Appendix B - Brownfields and Technical Support Contacts
The Brownfields and Technical Support Contacts page includes links to up-
to-date information for individuals at state, tribal and EPA national and
regional levels who are available to assist cleanup and redevelopment
efforts at brownfields sites. The individuals are a valuable resource for
brownfields stakeholders by providing support and guidance on
applicable laws, regulations and policies and technical assistance
associated with the selection of technologies.
Appendix C - Acronyms and Glossary of Key Terms
A list of acronyms and a detailed glossary of specialized terms used in
discussing and describing brownfields cleanup efforts is available on the
Brownfields Road Map website.
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